Ten years after the introduction of the Construction (Design and Management) Regulations 2015, there can still be misunderstanding about what the Principal Designer actually does.
For some projects, the appointment risks becoming an administrative exercise: appoint a Principal Designer, produce pre-construction information, compile a health and safety file and satisfy the requirements of CDM.
But that misses the central purpose of the role.
The Principal Designer should influence how health and safety risks are identified, eliminated, reduced and coordinated while design decisions are still being made.
When is a Principal Designer required?
Under CDM 2015, where a construction project involves — or is likely to involve — more than one contractor, the client must appoint a Principal Designer and Principal Contractor.
The Principal Designer must be a designer with control over the pre-construction phase and possess the skills, knowledge and experience — and, for an organisation, organisational capability — necessary for the project. HSE
This is important because the role isn’t intended simply to provide independent health and safety oversight.
It is fundamentally connected with design risk management.
The best opportunity to control risk is often before construction
Once a project reaches site, many important decisions have already been made.
Plant locations have been selected. Roof access has been determined. Structural arrangements have been designed. Services have been routed. Maintenance access has been created — or perhaps overlooked.
Changing those decisions once construction is underway can be expensive and disruptive.
During design, however, there may still be an opportunity to eliminate the problem altogether.
Imagine three air-conditioning units are proposed on a roof.
Looking only at installation might identify lifting operations and working at height.
A good design review goes further.
How will technicians access those units for routine maintenance? Are they positioned close to a fragile rooflight? Can components be removed safely? Will future replacement require a crane? Are suitable lifting points available? Has the structure been checked for the imposed loads?
These are foreseeable issues arising from the design.
Coordination is where the role becomes valuable
Modern projects rarely involve a single designer.
Architectural, structural, mechanical, electrical, fire and specialist designs frequently develop simultaneously.
A decision made by one discipline can create a risk for another.
The Principal Designer therefore needs to encourage designers to communicate and identify where interfaces create additional risk.
A new item of plant may increase structural loading.
A service penetration may affect fire compartmentation.
A revised access route may introduce exposure to a fragile surface.
A structural alteration may conflict with existing services.
Individually, each designer may have completed their work correctly. The risk appears at the interface between designs.
That is why coordination matters.
Building safety is placing even greater emphasis on competence
The wider regulatory environment has also changed considerably since CDM 2015 was introduced.
Building regulations now place explicit competence requirements on individuals and organisations undertaking design and building work. Government guidance states that individuals must have the necessary skills, knowledge, experience and behaviours, while organisations must demonstrate appropriate organisational capability. GOV.UK
HSE’s Building Safety Regulator training similarly emphasises the roles of clients, Principal Designers and Principal Contractors, individual and organisational capability, and the relationship between the newer building-regulations dutyholder regime and CDM 2015. HSE Training
Clients therefore need to consider more than whether somebody is willing to accept an appointment.
They need to consider whether they are capable of carrying it out.
What should effective Principal Designer involvement look like?
On a well-managed project, the Principal Designer should be visible in the design process.
That can include reviewing pre-construction information, identifying information gaps, coordinating significant design risks, challenging designers where hazards could reasonably be eliminated or reduced, recording significant residual risks and ensuring relevant information reaches those who need it.
Just as importantly, the process should remain proportionate.
CDM does not require designers to produce enormous risk registers containing every conceivable hazard.
Routine construction risks that competent contractors would normally be expected to manage do not need unnecessary paperwork.
The focus should remain on significant, unusual or difficult-to-manage risks and the decisions that can genuinely influence them.
Design risk management is not about eliminating every risk
Construction inevitably involves risk.
The objective is not to create a theoretically risk-free project. It is to make sensible design decisions that eliminate foreseeable risks where reasonably practicable and reduce or communicate those that remain.
That requires judgement, collaboration and, occasionally, the willingness to challenge a proposed design.
Done properly, the Principal Designer role can improve far more than regulatory compliance.
It can reduce redesign, prevent late changes, improve buildability, make maintenance safer and create better information for contractors and future building users.
From compliance to good design
The most effective approach to CDM is not to treat health and safety as something added to a finished design.
It should form part of the design process itself.
At Adept Safety, we believe good health and safety management should support projects rather than obstruct them. Early involvement, effective design coordination and proportionate risk management can help clients and project teams meet their responsibilities while delivering safer, better-planned projects.
The Principal Designer shouldn’t simply record risk. The role should help design it out.